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Anti-Corruption Policy

This anti-corruption policy (the “Policy”) is applicable to Floatel International Ltd. and its majorityowned subsidiaries and joint ventures (collectively the “Company”).

It is the Company’s Policy to:

Prohibit its employees, principals, directors, partners, officers and advisors (collectively “Personnel”) from offering, promising, making, authorizing or providing (directly or indirectly, including through Third Parties) any payments, gifts, or transfers of anything of value to any Public Official, including a person known to be (i) an immediate family member of a Public Official or (ii) a former Public Official, in order to improperly influence or reward any official action or decision by such person for the Company’s benefit. Neither funds from Company nor funds from any other source may be used to make any such payment or gift on behalf of or for the benefit of the Company;

Prohibit Personnel from offering, promising or giving (directly or indirectly, including through Third Parties) any payments, gifts or transfers of anything of value to any Private Sector Counterparty Representative in order to induce or reward that person’s improper performance of their function or activity; and

Comply with the applicable provisions of the U.S. Foreign Corrupt Practices Act, the U.K. Bribery Act and all other applicable anti-corruption laws that relate to the prohibition of payments to Public Officials or Private Sector Counterparty Representatives.

Failing to abide by this Policy can result in serious financial and criminal penalties for the Company and its Personnel. In addition, violations of this Policy may subject the involved Personnel to disciplinary sanctions. It is therefore imperative that all Personnel comply with this Policy and consult the Chief Financial Officer if there is any doubt about whether an activity is permitted.

If any Personnel knows or learns of a violation of applicable anti-corruption laws or of this Policy, he or she must promptly report the facts to the Chief Financial Officer or use the Company’s ethics hotline

Whistleblower/Ethics Hotline

All Floatel employees are encouraged to report any breaches of Floatel’s Policies or any suspected illegal activities to his/her Manager or Supervisor.
If you discover anything you want to report:

In first hand, refer to the Open Door Policy.

If the Open Door Policy is not suitable, and you feel you cannot report your discoveries to a
Manager or Supervisor, then please use the external Whistleblower e-mail address as described
below.

The Whistleblower e-mail address shall be used only in cases when the Open Door Policy is not sufficient and when breaches of Floatel’s Policies or suspected illegal activities are conducted by a Manager or a person in a key position.

The Whistleblower e-mail is administered by an external and independent law firm in Norway (Wikborg Rein, hereinafter WR) and Floatel has no access to the received e-mails. WR will evaluate each e-mail and forward relevant facts to Floatel in order to further investigate an alleged breach of a Policy or an illegal activity.

You have the right to remain anonymous, in which case WR will not disclose your name or contact details to Floatel.

How to Report Allegations

A request to remain anonymous, if you do not want WR to disclose your name to Floatel.

If you approve that WR disclose your name to Floatel, please provide your name and state on which vessel or in which office you work. Please also leave your contact details in case further clarifications regarding the matter are needed.

Name and Position of the person subject to the allegations, including vessel or office where the person works.

Detailed description of the circumstances forming basis of the allegations.

The allegations will be forwarded through e-mail to Floatel’s General Counsel without any modifications, provided that you have not required to be anonymous. In such case WR will print and disguise the message to unable identification and then forward the message as a scanned copy to Floatel.

The information will be processed in accordance with the Swedish Personal Data Act (1998:204).